Beyond Regulatory Compliance.

Enhancing Environmental Health with an Education Paradigm

Abstract

When regular business procedures provide for quality environmental and public health, the need for regulatory intervention is reduced. The regulatory environmental health practitioner can play a key role in teaching and motivating businesses to adopt operational procedures that proactively promote environmental health. Within regulated businesses, environmental health practitioners can provide the evaluations and assessments needed to propel their businesses beyond the requirements and into innovative environmental health practices. Currently, changes in the attitudes of society toward environmental health problems are driving businesses to advance beyond regulatory compliance in providing environmentally healthy services, safe workplaces, and low-impact products. The role of the environmental health practitioner is to facilitate this movement away from the traditional, or regulatory, paradigm and toward a participatory, adult-learning model--the education paradigm. Putting theory into practice requires knowl edge and application of adult-learning strategies practiced by health educators. Although studies of this paradigm shift are still in progress, results thus far are encouraging.

Introduction

During the 20th century, the quality of environmental and public health has come a long way in the United States. The legislative and rule-making process has been crucial to this improvement. To ensure safe products, workplaces, homes, and environments, environmental health practitioners in industry, business, and government have relied on monitoring compliance with regulations and rules (Table 1). Time and energy are spent on spot checks, random sampling of final products, and surveys of environmental media and ambient conditions. This regulatory paradigm works through a reactive system that addresses problems as they arise, rather than a preventive and participatory system that anticipates and intervenes before harm occurs.

Reactive environmental health practices are labor and dollar intensive and may not provide optimal protection. In addition, the last couple of decades have brought about hidden incentives for government and industry to shift toward proactive environmental health programs. Environmental legislation (i.e., community-right-to-know legislation) has given the public the right to information about compliance and operations. The Internet gives the public easy access to government databases that collect environmental protection and safety records from the regulated community (e.g., the Toxic Release Inventory). The popular press and information campaigns have brought environmental health issues to the attention of the public. Thus informed, the public is becoming increasingly risk-averse and is moving toward zero tolerance (rational or otherwise) of the impact industry, agriculture, and other businesses have on environmental health [1]. In this atmosphere, the traditional regulatory paradigm cannot provide the manpo wer, resources, or insight necessary to meet public demands.

Times Are Changing

The practice of proactive environmental health protection has found a foothold in today's industrial and regulatory climate. In several areas, environmental health practice is moving toward preventive strategies that combine risk assessment and risk management with risk education. The following programs are examples of how compliance checks can be de-emphasized in favor of a management style that minimizes problems before they occur:

* The U.S. Food and Drug Administration (FDA) has adopted the Hazard Analysis Critical Control Point (HACCP) method [2,3]. This multistep approach analyzes hazards for critical control point identification; establishes preventive, monitoring, and record-keeping measures; plans for corrective procedures; and institutes verification procedures.

* Member companies of the Chemical Manufacturers Association have adopted a program called "Responsible Care" [4,5]. This program combines a set of guiding principles with management practice codes to improve health, safety, and environmental performance in chemical manufacturing. At the same time, manufacturers are encouraged to bridge the communication gap between industry and the public by setting up community advisory panels. The Responsible Care Program goes beyond evaluating current practices; it also addresses current and future production, facility management, environmental protection, the needs of the community, and governmental regulation.

* Product stewardship builds customer-supplier partnerships in which manufacturers train customers how to safely handle, use, and dispose of their chemicals [6].

The number of voluntary programs for improving the quality of environmental health is limited, and the number of participants in these programs is small but growing. Some assistance programs, such as the U.S. Environmental Protection Agency's (U.S. EPAs) Partners for the Environment, offer incentives and expertise. These programs help businesses to incorporate practices that produce measurable environmental results in a timely and cost-effective manner. Guidelines developed by the International Organization of Scientists (ISO 14000), where used, can push industry beyond federal, state, and local regulations.

The Environmental Health Education Paradigm

As the demands for compliance increase and resources are constricted, the role of education is becoming more apparent. This approach was initiated in the area of food safety, but practitioners in all areas of environmental health need to recognize its benefits and incorporate education and training into their programs. Areas in which the education paradigm could be useful include

* food safety,

* pool safety,

* well or septic quality,

* manufactured housing,

* indoor air quality,

* lead exposure control,

* vector control,

* pollution prevention,

* general environmental health complaints, and

* community environmental health.

In addition to a strong educational component, any reform must incorporate support systems.

The education paradigm represents a shift in traditional roles and modes of operation and in the relationships between government-based environmental health practitioners and the entities they regulate. In the regulatory paradigm, the relationship often is contentious or adversarial (Figure 1). The education paradigm, by contrast, is characterized by a cooperative, participatory relationship (Table 2). Personal interactions are structured for dialogue, not didactics, and activities are based on the needs of the business and its capacities for advancing environmental health rather than on measurement of compliance. Additionally, a reactive find-and-fix mentality is replaced with a proactive approach. Maximum effectiveness will occur when this paradigm shift has the support of both the business community and the regulatory community.

Several basic benefits will result from the paradigm shift. Those being regulated will become more invested in achieving high-quality environmental health practices. These businesses are more likely to go beyond the basic requirements of laws and rules and to make innovative practices more central to the core competencies of their operation. After the initial learning phase, costs to the regulator and the business should decrease: Costs to the regulator may be reduced because of decreases in compliance visits, follow-ups, and paperwork. For those being regulated, costs (including liability, insurance, and environmental impact fees) may be reduced as benefits (community confidence, improved environmental health, reduced operating costs) mount. The joint effect may be an enhanced quality-of-work experience both for the regulated and for the regulator--creating greater job satisfaction. When education is the primary focus, expanded responsibility, autonomy, and innovation can become part of the job while strict regulatory compliance demands are reduced. This enhanced work quality could show up in reduced turnover.

The paradigm shift requires organizational change. The government environmental health practitioner, the regulated environmental health practitioner, and the community must agree to be flexible to achieve maximum benefit and overall environmental health. The educational focus must produce a self-audited process.

For self-audited environmental health reform to succeed within industry and business, both management and workers must both agree to the goals and procedures needed for proactive change. As with any process of change, those who would adopt the new paradigm must accept new ideas, acquire new skills, and be able to function in an environment that promotes new behaviors or procedures [7]. The absence of any of these capacities may compromise the rate of change.

The Educational Process

The effectiveness of an environmental health education paradigm is maximized when a comprehensive educational process is combined with a sound theoretical foundation. The educational process includes needs-and-capacity assessment, program planning, implementation, and evaluation (Figure 2).

Needs-and-capacity assessment is a data-generating process designed to define current practices in relation to desired performance. Areas for improvement (needs) and operations indicative of achievement (capacities) both should be assessed. The focus should be on improving environmental health practice through collaborations between the regulated community and the regulators. This kind of assessment helps establish priorities.

Program planning is based on the results of the needs-and-capacity assessment. The central activities of this phase include identifying goals and objectives, selecting instructional strategies, and adjusting and adopting policies. Also, decisions are made about the allocation of resources.

During implementation, the business and regulatory personnel work in tandem to develop the capacity of the organization. Activities may include in-service training (the articulation, dissemination, and implementation of new policies) and alteration of policies or physical environments.

Traditionally, the process of enforcing regulatory compliance would take place during the evaluation phase, but this phase also can focus on positive behaviors (e.g., enhancing food preparation systems or reducing waste products). The evaluation phase also serves as a starting point for the next cycle of the needs-and-capacity assessment.

The four steps of the educational process perform best when they work symbiotically Conceptually, the steps may seem to flow in a linear fashion, but each step depends on the other three and is affected by them. Thus, the first step, planning and conducting a needs-and-capacity assessment, must take into account program-planning issues (e.g., agency mission, selection of educational strategies, procurement and allocation of resources, budget). Undertaking a needs-and-capacity assessment without considering these issues could result in a misguided assessment that would establish priorities outside the areas of concern or beyond the capabilities of the agency.

Also, during the needs-and-capacity assessment, the target audience should be engaged, at least in data collection and, more ideally, in the formulation and application of the assessment process. This involvement helps initiate the implementation process because the assessment process can begin to change knowledge, skills, and abilities.

A final example of interdependence relates to the evaluation step. The entire educational process should be subject to ongoing process evaluation.

Instructional Strategies

The goal is to move those being regulated into a mode of self-inspection and compliance. A hierarchy of instructional strategies culminates in the realization of the education paradigm. The regulatory environmental health practitioner then facilitates compliance by supporting the self-directed educational initiatives of those being regulated (Figure 3).

The most basic instructional strategy is dissemination of literature, a widespread practice characterized by minimal learning and minimal transfer of meaningful skills. For the regulatory community and the regulated community alike, it is a passive process.

The next level in the hierarchy is one-on-one consultation. This strategy has an informal character and largely occurs in tandem with enforcement efforts. Individual interaction provides flexibility and requires solid interpersonal communication skills for maximum effectiveness.

During group consultations, the regulator interacts with small groups of people to facilitate learning. This, too, may be a fairly informal process stemming from enforcement, or it may be more proactive and planned. Group dynamics are important, and the facilitator must have the ability to engage group members in collaborative learning. Although the process focuses on the regulated business, the consultations are still largely regulator driven.

A business that has begun to recognize inherent needs may organize in-service training to redress inefficiencies, update procedures, or--more optimistically--advance capacities. The point is that the business has taken a proactive role and seeks improvement in environmental health practice. At this stage, the regulatory environmental health practitioner assumes a more supportive role, encouraging the process but not necessarily delivering the training. The business environmental health practitioners control much of the learning.

In-service training can lead to self-study (or can be initiated by self-study) when the business critically and systematically assesses current practices with the intention of changing or improving them. Self-study epitomizes the education paradigm because the business has assumed responsibility for its environmental health practice and is invested in achieving higher levels of performance.

The result of self-study should be an action plan for changing operations, policies, or procedures to enhance regulatory compliance. Additionally, improved efficiency will make self-inspection and compliance into core functions of the business.

At this stage, the regulatory environmental health practitioner continues to support the educational process, review the inspection proceedings, and confirm compliance. In essence, the regulator's role has been inverted, but it still achieves the ultimate goal. Enforcement and monitoring of compliance have been minimized. Education and collaboration have been maximized, and environmental health is maintained or improved.

Adult-Learning Principles

Adult learners feel the need to perceive the goals of learning as consistent with their personal goals. Also, adults want to participate actively in the learning process, accept responsibility for the planning and operation of learning, and integrate their experience into the learning process. The educational process is further enhanced when adults can put learning into immediate practice, see results, and receive accurate feedback. This kind of involvement makes learning more relevant and improves retention and application [8,9].

Individualization is often a goal of educational strategies, but particularly for adults because of the varied learning styles and life experiences encountered in almost any workplace. An environmental health education paradigm therefore would consider both the business and the individual throughout the process (i.e., needs-and-capacity assessment through evaluation).

The utility of adult-learning principles is evidenced by the variety of situations that have successfully integrated its elements. Adult-learning initiatives reported in the literature include adult literacy programs, general equivalency education, technology, foreign-language instruction, English language acquisition, and agriculture [10--14].

Following are some recommendations for developing an education paradigm based on adult-learning principles:

* Allow a high level of participant control in the selection of content and learning methods [15]. This approach might, for example, involve participants in conducting needs-assessment strategies and in writing learning objectives.

* Focus on developing skills that are important and immediately relevant to the work environment or that will clearly be of use in the near future. Developing abilities that lead to advancement or promotion is appealing for adults. Suggestions include using job performance criteria as a basis for education and placing a special emphasis on criteria for positions that involve additional responsibility or offer advancement.

* Provide choices and alternatives during the implementation phase. Participant involvement must not stop after needs-and-capacity assessment or program planning. Flexibility (i.e., individualization) must also characterize implementation [16]. Structurally, this recommendation might entail beginner and advanced training tables. Another possibility is to offer activity areas at which participants who have similar job responsibilities can collaborate.

* Learning activities need to allow for self-expression and sharing of experiences. Small groups and collaborative learning are particularly well suited to this kind of activity [17]. Participants' self-expression might take the form of presenting case studies or problems based on work experience.

* Assessment of learning should rely heavily on self-assessment and should minimize external judgement of the participant. Journal writing or portfolios can serve as valuable, authentic assessment tools [18,19]. An added benefit is the generation of a product the participant can use to document learning and to continue self-study even after the structured educational experience.

Conclusion

Adopting an education paradigm requires change, which in turn requires a supportive organizational culture. Regulatory environmental health practitioners must develop new skills or must collaborate with those who already have the skills needed to institute an education paradigm. Also, environmental health regulators should team up with other programs that may already be using the education paradigm. Building coalitions will stretch resources and take advantage of others' experience.

Environmental health practitioners who work through local health departments may be able to draw on the knowledge of health educators, who often work in those departments. Health educators are skilled in the basic elements of the educational process, and they are trained to build educational programs. Thus, collaboration between the environmental health practitioner (content expert) and the health educator (process expert) could integrate the educational process into proactive environmental health practices for regulated businesses [20]. The effort required to establish such collaboration would be worthwhile. The education paradigm represents a most promising future for all concerned with successful environmental health practice.

Corresponding Author: Sharron LaFollette Ph.D., Illinois State Univ., Dept. of Health Sciences.

REFERENCES

(1.) Sandman, P. (site found March 13, 1999), "Risk Communication, <http://www.quest.com.au/QuestPeterSandman.htm>.

(2.) U.S. Food and Drug Administration (site found March 13, 1999), "A State of the Art Approach to Food Safety," <http://vm.cfsan.fda.gov/lrd/fdahaccp.txt>.

(3.) Pierson, M.D., and D.A. Corlett, Jr. (1992), HACCP Principles and Applications, New York: Chapman and Hall.

(4.) Ember, L.R. (1995), "Responsible Care: Chemical Makers Still Counting on It to improve Image," Chemical and Engineering News, 73:10-19.

(5.) Hook, G.E.R. (1996), "Editorial: Responsible Care and Credibility," Environmental Health Perspectives, 104(11):1138-1139.

(6.) Borchardt, J.K. (1998), "Customer Chemical Health and Safety Education: A Tool for Competitive Advantage," Chemical Health and Safety, 5(2):20-23.

(7.) Rogers, E.M. (1983), Diffusion of Innovations, 3rd ed., New York: Free Press.

(8.) Wood, F.H., and S.R. Thompson (1980), "Guidelines for Better Staff Development," Educational Leadership, 37:374-378.

(9.) Orlich, D.C. (1989), Staff Development: Enhancing Human Potential, Boston: Allyn and Bacon.

(10.) Lytle, S.L. (1994), Literacy Practitioner: Assessment Issue, 2(1).

(11.) Office of Vocational and Adult Education (1994), Models of Excellence in Adult Learning: Recipients of the 1994 Secretary's Award for Outstanding Adult Education and Literacy Program, Washington, DC: Division of Adult Education and Literacy (ERIC Document Reproduction Service No. ED 382827).

(12.) Tomlin, M.E. (1997), "Changing what and how we teach for a changing world," Adult Learning, 8(5/6):19-21.

(13.) Keating, K. (1994), "Findings from a Qualitative Study of Adult Learners of Spanish: Implications for Approaches to Second Language Programs for Future Teachers," Journal of Instructional Psychology, 21:57-63.

(14.) Weeks, T. (1996), "Georgia Young Farmer Programs Provide Life-Long Learning," Agricultural Education Magazine, 68:8-10.

(15.) Verduin, J.R., H.G. Miller, and C.E. Greer (1986), The Lifelong Learning Experience, Springfield, IL: Charles E. Thomas.

(16.) Pilling-Cormcik, J. (1997), "Transformative Self-Directed Learning in Practice," New Directions for Adult and Continuing Education, 74:69-77.

(17.) Burke, K. (1997), "Responding to Participants' Learning Styles During Staff Development," Clearinghouse, 70(6):299-301.

(18.) Williamson, A. (1997), "Reflection in Adult Learning with Particular Reference to Learning-in-Action," Australian Journal of Adult and Continuing Education, 37(2): 93-99.

(19.) Hayes, E. (1997), "Portfolio Assessment in Adult Basic Education: A Pilot Study," Adult Basic Education, 7(3):165-188.

(20.) Breckon, D.J., J.R. Harvey and R.B. Lancaster (1994), Community Health Education: Settings, Roles, and Skills for the 21st Century, 3rd ed., Gaithersburg, Md.: Aspen.

   The Traditional Regulatory Paradigm for Environmental Health Practice
Regulatory Practices                   Limits
Inspection
 Occurs regularly or unannounced       Limited relationship building
 Identifies quality of compliance      Frequency often drive by complaints or
                                       outbreaks
Compliance
 Identified by agreement, resolution,  Negotiated--not necessarily ideal
 or cooperation
Re-Inspection (Follow-up)
 Prioritizes violations                Option of inspector
 Establishes correction                Doesn't ensure compliance in a timely
                                       manner
Enforcement Procedures (Potential)
 Conference/meeting                    Prolongs time to compliance
 Hearing                               May shut down business
 Questioning/suspension of a permit
 Penalty or reinspection
   A Participatory-Education Paradigm for Environmental Health Practice
The Education Process                  Benefits
Needs-and-Capacity Assessment
 Establishes priorities                Targeged, efficient use of resources
 Identifies improvements (needs) and   Enhanced opportunity for success
achievements (capacities)
 Focuses on collaboratively working
with service providers to
  improve environmental health
practices
Program Planning
 Identifies goals and objectives       Clarifies the direction of efforts
 Selects instructional strategies      Meaningfully involves all stakeholders
                                       in a proactive process
 Adjusts/adopts policies
 Decides resource allocation
Program Implementation
 Joint effort of service providers and Mutually supportive collaboration
regulatory practitioners
 May include in-service training;      Comprehensive and coordinated efforts
articulation, dissemination, and
  implementation of new policies; or
alteration of physical environments
Evaluation
 Traditional regulatory compliance     Increases likelihood of positive
                                       change
 Focus on positive behavior            Takes environmental health practices
                                       beyond the limitations of regulations
 Serves as starting point for new
cycle of needs assessment
  and capacity building